Commenting on Agency Rules

The TCEQ, RRC and EPA frequently propose new rules they intend to adopt. These proposed rules have specific comment time periods, during which members of the public (i.e. you) can make comments, objections and suggested changes. The agencies consider these comments and respond to them, sometimes changing the proposed rule before adopting it in its final form.

These agencies generally do not know the particulars of your business and they often do not consider all business concerns in their initial drafting. Not surprisingly, sometimes proposed rules are just not workable.

As you decide whether or not to participate in rulemaking projects, your competitors are probably undertaking same analysis.  If you or your business may be affected by a proposed agency rule, the saying goes “if you’re not at the table, you’re on the menu.”  This means that if you don’t participate by understanding the rule proposal, and submit comments designed to tailor the proposed rule to your benefit or minimize its negative effect on you, then you are at risk of being harmed, maybe dramatically.

 

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